Case Digest (G.R. No. 112719)
Facts:
The People of the Philippines v. Ernesto Omotoy y Cariaga, G.R. No. 112719, January 29, 1997, Third Division, Narvasa, C.J., writing for the Court. The prosecution (the People of the Philippines) charged accused-appellant Ernesto Omotoy with arson under Presidential Decree No. 1613, Section 3(2), for allegedly setting fire on the inhabited house of Rosario Mirafuente on July 6, 1986, resulting in total destruction and P7,500.00 in claimed losses. The information alleged conspiracy with unidentified others and that the Mirafuente family was inside the house when it was set afire.On the night of July 6, 1986, witnesses Rosario and Editha Mirafuente and Rosario’s brother Arthur testified that stones were hurled at the Mirafuentes’ two‑storey house, that several men were in the yard and that they recognized Omotoy among them; they said Omotoy returned and called Rosario out and set the cogon roof on fire with a match. The area was illuminated by an exterior electric bulb nearby. Rosario escaped to the woods; his wife and children fled to Rosario’s parents’ home. The next day Rosario identified Omotoy at the scene. Police statements were taken.
Omotoy denied the charge and asserted an alibi, claiming he was attending his seriously ill wife at home and later at a clinic; his mother‑in‑law and other relatives corroborated this. Defense witnesses included Barangay Captain Catalino Marcos and Councilman Alfredo Tomaneng, who testified that when they investigated on July 7 the Mirafuentes did not name any suspect. Omotoy was not arrested until January 24, 1990; he was arraigned February 26, 1990, and trial followed.
The Regional Trial Court (Second Judicial Region, Branch 6, Judge Benedicto A. Paz) found the prosecution witnesses more credible, disbelieved the barangay officials because of bias (both were closely related to Omotoy), rejected the alibi as unpersuasive (Omotoy’s house was only about 100 meters away), and convicted Omotoy on July 5, 1993, for violation of PD No. 1613, Section 3(2), sentencing him under applicable provisions and the Indeterminate Sentence Law and ordering indemnity of P7,500. The trial court’s judgment increased bail and weighed as an aggravating circumstance spite or hatred under PD No. 1613, Section 4 ¶3.
Omotoy appealed directly to the Supreme Court (the appeal reached this Court despite the usual route to the Court of Appeals because a penalty of reclusion perpetua had been imposed). He raised three errors: (1) that the trial court erred in rejecting the barangay officials’ testimonies; (2) that the prosecution’s evidence was grossly insufficient; and (3) that conviction under PD...(Subscriber-Only)
Issues:
- Did the trial court commit reversible error in discounting the testimonies of Barangay Captain Catalino Marcos and Councilman Alfredo Tomaneng?
- Was the evidence presented by the prosecution insufficient to establish Omotoy’s guilt beyond reasonable doubt?
- Was conviction under PD No. 1613, Section 3(2) improper because the prosecution did not prove the property was in an urban center or that the offender was a criminal syndicate, and was th...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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